EASE has provided a response to ENTSO-E Public Consultation on the All Continental Europe TSO’s proposal to determine a minimum activation time period required for limited energy reservoirs to remain available during alert state in accordance with Article 156(11) of the SO GL. Although several flaws in the methodology have been detected, EASE has suggested reasessment of the methodology to enhance the proposal.
September 2021 / Policy Papers
Third Gas Package Revision: EASE Proposals for a Decarbonised Gas Market
The European Commission announced in its 2021 Working Programme that the Third Gas Package will be revised to regulate competitive decarbonised gas markets: EASE believes that energy storage solutions such as Hydrogen and Power-to-Gas will play a key role in the transition of the gas system, and sees the proposed revision as a great opportunity to enhance sector integration as well as the deployment of renewable carbon gases, as already stated in the Reply to the Public Consultation on the Hydrogen and Decarbonised Gas Market Package.
This document presents revision of the Third Gas Package in two sections. To read about the high level policy decisions needed to reshape the energy system, taking into account Power-to-Gas role, head to Chapter 1. To discover the specific regulatory changes necessary to improve the Power-to-Gas legislation at the EU level, head to Chapter 2.
The first part of the paper focuses on a few, key high-level messages that can help decision-makers design a new gas market that is inclusive of Hydrogen and Power-to-Gas storage solutions:
Develop an energy storage definition for the gas sector;
Develop technology neutral definitions for renewable and low-carbon gases;
Rely on a market-based approach for PtG;
Ensure that the new Package is in line with the EU Strategy on Energy System Integration;
Strengthen European R&D&I.
The second part of the paper collects specific suggestions which tackle different challenges for the Hydrogen and Decarbonised Gas Market Package:
Infrastructure planning;
Market regulation;
Guarantees of origin;
Consumers and communities;
Gas quality and blending;
Hydrogen trade and imports;
Security of supply.
The document is thoroughly analysed and the different proposals aim at supporting policymakers taking into account the storage industry’s take on the upcoming revision, making sure to untap the potential of energy storage technologies, especially Power-to-Gas, in decarbonising the gas sector.
EASE has provided a response to ENTSO-E Public Consultation on the All Continental Europe TSO’s proposal to determine a minimum activation time period required for limited energy reservoirs to remain available during alert state in accordance with Article 156(11) of the SO GL. Although several flaws in the methodology have been detected, EASE has suggested reasessment of the methodology to enhance the proposal.
Energy Storage Europe has prepared a reply to the European Commission's public consultation on TYNDP 2026 Identification of System Needs Methodology. The European Commission’s public consultation seeks feedback on the analytical framework used by ENTSO-E to identify cost-efficient and technically robust opportunities for the development of Europe’s electricity system, without prescribing specific investment decisions.
In 2025, the energy storage sector experienced significant growth, driven by strong market expansion and evolving EU policy developments. Europe reached the milestone of 100 GW of installed capacity, highlighting the increasing importance of storage in the energy transition.
Energy Storage Europe replies to the European Commission’s public consultation on the Battery Booster Facility. On 16 December 2025, the European Commission announced a Battery Booster Strategy, within the Automotive Action Plan. The Strategy includes a Facility of EUR 1.5 billion in the form of loans for projects in the production of battery cells in Europe.
Energy Storage Europe's position paper, "Ensuring System Stability in Europe: The Role of Energy Storage in Providing Inertia", focuses on how the EU can implement a cost-effective and technologically neutral approach to procuring inertia. It also outlines how such an approach can be firmly embedded within a harmonised European methodology for assessing and monitoring inertia needs across synchronous areas.
